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Mr. Howard Hold <br /> August 27, 2004 <br /> Page 2 <br /> were necessary because the property owner(the owner of the property south of Littlejohns Creek <br /> and adjacent to the western border of SMS Briners, Arnold Sousa, has indicated firm opposition <br /> when an inquiry was made to him concerning well installation on his property). <br /> Proposed Monitoring Well Locations <br /> Based on the historical record for ground-water flow directions and the estimated extent of <br /> ground-water quality impacts in the shallow and deep zones (LSCE, 2003), the initially proposed <br /> locations for the new facilities were as follows: <br /> • Shallow Completion: approximately 600 feet west-southwest of the southwest comer of <br /> the south pond, <br /> • Shallow Completion: approximately 750 feet east of the northeastern corner of the north <br /> pond,just west of the access road to the facility, <br /> • Deep and Shallow Completions: approximately 750 feet northwest of the northwestern <br /> corner of the north pond, <br /> • Shallow Completion: approximately 500 feet south of the south pond(south of <br /> Littlejohns Creek). <br /> As a result of the opposition by the property owner(Sousa) who owns property where four of the <br /> five monitoring wells were initially sited, significant adjustments to the planned drilling program <br /> have been required. The new proposed locations are shown on Figure 1. <br /> The proposed wells are now sited on land owned by Kruger Foods,Inc. The main objective of <br /> the proposed new facilities is to refine the understanding of the ground-water zone affected by <br /> the release of saline water in the vicinity of the ponds. Historical data have allowed an <br /> estimation of the plume extents; the proposed wells are planned to, in conjunction with other site <br /> data, delineate the limit of the plume. As described below, additional monitoring may be <br /> recommended as a later phase for purposes of further characterizing the limit of the plume or for <br /> the connective action monitoring program. The objectives for monitoring at the new locations <br /> include: <br /> • MW5A: Background monitoring is presently occurring at MW2. Based on the data <br /> collected at this location since 1989, a Water Quality Protection Standard (WQPS)of 89 <br /> mg/L chloride has been established for the shallow zone. Previously, the direction of <br /> ground-water flow shifted during the year; however, there has been a more recent <br /> tendency for the ground-water flow direction to be northwesterly or in the direction of the <br /> current background monitoring well. To ensure that a suitable background monitoring <br /> well for the shallow zone is available to collect future background data, MW5A is <br /> proposed at a location upgradient and somewhat cross-gradient of the ponds. Based on <br /> the historical water quality data from this site, the proposed location of MW5A should be <br /> far enough from the plume to have not been impacted from historical pond operations <br /> and/or the influence of historical ground-water flow directions. Additionally, baseline <br /> testing at monitoring well MW5A can then be compared to the historical data for MW2 <br />